MarineLog hosted the Global Greenship conference September 17 & 18, 2009 at the Washington Marriott Hotel. This environmental conference had a number of interesting presentations and covered a wide spectrum of environmental concerns.
Matters discussed were the coming North America ECA (coastal and inland waters) and environmental compliance enforcement from the perspective of the USCG and the US Dept. of Justice. Green issues covered were exhaust gas scrubbing, marine paints, hybrid propulsion, inland barge transport's smaller carbon footprint and the proposed ballast water discharge standards by the USCG.
I was surprised to be the only Canadian at this conference.
Showing posts with label ECA. Show all posts
Showing posts with label ECA. Show all posts
Monday, September 21, 2009
Monday, August 31, 2009
EPA's proposed rulemaking
On August 28, 2009 the US EPA posted the proposed rulemaking for ECA compliant air emissions in the internal waters of the USA.
I did not read the full text of the ECA document, but had some e-mail exchanges with a US consultant.
The question I had was in regard to ECA compliance for the St. Lawrence Seaway. As everyone knows, there is no provision for innocent passage in an ECA, the ship has to comply with the ECA requirements. Which for a Canadian ship sailing from Montreal to Lake Ontario means it has to meet with the EPA imposed emission criteria. The implications are that with a rigid ECA application, Canadian ships would need to conform with US emission requirements on internal trade.
Dennis Bryant suggests that there is nothing limiting the EPA from issuing a waiver to Canadian Lakers on the ECA requirements; which would be a nice, neighborly gesture.
The wild card in all of this is the states' liberty to impose more stringent requirements for their waters, as they did in the VGP. The question I have then, could New York void the EPA's waver on ECA compliance for Canadian Lakers by insisting on ECA compliance?
I did not read the full text of the ECA document, but had some e-mail exchanges with a US consultant.
The question I had was in regard to ECA compliance for the St. Lawrence Seaway. As everyone knows, there is no provision for innocent passage in an ECA, the ship has to comply with the ECA requirements. Which for a Canadian ship sailing from Montreal to Lake Ontario means it has to meet with the EPA imposed emission criteria. The implications are that with a rigid ECA application, Canadian ships would need to conform with US emission requirements on internal trade.
Dennis Bryant suggests that there is nothing limiting the EPA from issuing a waiver to Canadian Lakers on the ECA requirements; which would be a nice, neighborly gesture.
The wild card in all of this is the states' liberty to impose more stringent requirements for their waters, as they did in the VGP. The question I have then, could New York void the EPA's waver on ECA compliance for Canadian Lakers by insisting on ECA compliance?
Tuesday, June 9, 2009
MEPC 59
IMO posted document MEPC 59/1/2, dated June 1, 2009.
The Note by the Chairman proposes the following arrangements for the working, drafting and other groups at MEPC 59:
The GHG issue is one area where the the Friends of the Earth Int'l and other NGOs are pushing hard for progress, asking for considerable fuel consumption reductions.
The Drafting Group for amendments to MARPOL Annex I suggests tightening of the oil pollution regulations. It should be noted there is a US proposal before the MEPC 59 to phase out MEPC.60(33) compliant bilge filtering equipment.
Does the Technical Group on ECA and other Annex VI issues suggest a planned global approach to ECA designations? If so, could it delay passage of the US - Canada application at MEPC 59.
The Note by the Chairman proposes the following arrangements for the working, drafting and other groups at MEPC 59:
- Working Group on GHG Issues;
- Working Group on Guidelines for Ship Recycling;
- Joint MSC/MEPC Working Group on Human Element;
- Drafting Group on Amendments to MARPOL Annex I; and
- Technical Group on Emission Control Area (ECA) and other MARPOL Annex VI related issues.
The GHG issue is one area where the the Friends of the Earth Int'l and other NGOs are pushing hard for progress, asking for considerable fuel consumption reductions.
The Drafting Group for amendments to MARPOL Annex I suggests tightening of the oil pollution regulations. It should be noted there is a US proposal before the MEPC 59 to phase out MEPC.60(33) compliant bilge filtering equipment.
Does the Technical Group on ECA and other Annex VI issues suggest a planned global approach to ECA designations? If so, could it delay passage of the US - Canada application at MEPC 59.
Wednesday, May 27, 2009
USCG preparing for MEPC.59
Dennis L. Bryant sent me the link to the proposed Shipping Coordinating Meeting in Washington, DC on June 26, 2009.
The purpose of the meeting is to prepare for the 59th session of the International Maritime Organization (IMO) Marine Environment Protection Committee (MEPC.59) to be held at IMO's London head quarters July 13-17, 2009. One of the agenda items of the June 26 meeting is the ECA proposal, which the USA submitted jointly with Canada.
The purpose of the meeting is to prepare for the 59th session of the International Maritime Organization (IMO) Marine Environment Protection Committee (MEPC.59) to be held at IMO's London head quarters July 13-17, 2009. One of the agenda items of the June 26 meeting is the ECA proposal, which the USA submitted jointly with Canada.
Monday, May 11, 2009
Joint ECA submission USA/Canada
The United States submitted a document in support of the proposal to designate an Emission Control Area for specific portions of the coastal waters of the United States and Canada. It provides references and other information considered in developing the proposal.
The document is listed MEPC 59/INF.13, dated April 9, 2009. It was posted on the IMO Documents Website May 11, 2009
The document is listed MEPC 59/INF.13, dated April 9, 2009. It was posted on the IMO Documents Website May 11, 2009
Thursday, May 7, 2009
More on climate change
I have a hard time accepting an East Coast ECA, while excluding the Arctic, because the Arctic is the most vulnerable environment with the least buffering. It is the region most affected by climate change already, as average temperature changes there are outpacing all other regions on the globe.
The World Health Organization (WHO) is concerned about the fate of low lying coastal areas and low lying Pacific Islands, which are already seriously affected by rising sea levels. In their document titled "Health and Environment: Managing the Linkages for Sustainable Development", WHO provides “A Tool Kit for Decision Makers”. WHO discuss major environmental risk factors with quantifiable disease impacts, attributing 150,000 excess deaths annually to climate change.
James E. Hansen has written many articles on the subject of air pollution. In his 2003 piece "As pure as snow" he explains the effect dirt on snow. When I saw the ECA submission I asked him whether we should be concerned about PM emissions from more ships sailing into Churchill. Two of his colleagues came back and concurred that we should be concerned. One of them, Mark Flanner in his e-mail reply said "I am currently working with some folks here at NCAR [National Center for Atmospheric Research, Boulder, Colorado] and NOAA [National Oceanographic and Atmospheric Administration] to quantify impacts on sea-ice of future Arctic shipping. Also, shipping emission scenarios (including Arctic sources) are currently being drawn-up for inclusion in studies for the next IPCC [Intergovernmental Panel on Climate Change] report." – These are people who know; maybe Canada should listen to science and consider the WHO concerns about climate change. Maybe we should look for an ECA solution that doesn't divert traffic into the Arctic?
The World Health Organization (WHO) is concerned about the fate of low lying coastal areas and low lying Pacific Islands, which are already seriously affected by rising sea levels. In their document titled "Health and Environment: Managing the Linkages for Sustainable Development", WHO provides “A Tool Kit for Decision Makers”. WHO discuss major environmental risk factors with quantifiable disease impacts, attributing 150,000 excess deaths annually to climate change.
James E. Hansen has written many articles on the subject of air pollution. In his 2003 piece "As pure as snow" he explains the effect dirt on snow. When I saw the ECA submission I asked him whether we should be concerned about PM emissions from more ships sailing into Churchill. Two of his colleagues came back and concurred that we should be concerned. One of them, Mark Flanner in his e-mail reply said "I am currently working with some folks here at NCAR [National Center for Atmospheric Research, Boulder, Colorado] and NOAA [National Oceanographic and Atmospheric Administration] to quantify impacts on sea-ice of future Arctic shipping. Also, shipping emission scenarios (including Arctic sources) are currently being drawn-up for inclusion in studies for the next IPCC [Intergovernmental Panel on Climate Change] report." – These are people who know; maybe Canada should listen to science and consider the WHO concerns about climate change. Maybe we should look for an ECA solution that doesn't divert traffic into the Arctic?
Friday, May 1, 2009
CMAC meetings
I sat in on two days meetings on the environmental side of this spring’s CMAC meeting in
In the Ballast Water working group a comment was made that no ballast Water Treatment System had been tested, specifically in fresh water. The assumption was voiced that therefore reliable performance of such systems was not guaranteed. RWO have submitted their application for approval and it is expected that approval will be issued at the July MEPC session.
- The system was tested in
In the Air Emissions working group, Environment Canada summarized the benefits from an ECA, referring to some 159 lives saved with total health benefits of $ 900 Million per annum.
The health problems are, to a large degree, caused by particulate matter. The latest Environment Canada statistic shows PM from marine transport at 10,404.9t out of 18,377,707.2t for all of
Environment Canada gives some interesting graphs on Canadian pollution, which may provide some additional reference as to how skewed the ECA proposal is.
At the standing committee on the environment, Environment gave a presentation on the current Bill C-16. Below is the link to the bill, and underneath a link to an opinion by one of the marine lawyers.
If the industry was concerned about Bill-15, the amendment to the migratory bird act, I feel 16 indicates that this is Bill 15 on steroids.
Monday, April 27, 2009
ECA, Pink Floyd and Leonard Cohen
This post was published in the April 20th 2009 issue of Canadian Sailings.
With the recent proposal by Canada and the United States for a North American Emission Control Area, Pink Floyd’s “Is There Anybody Out There?” comes to mind. When reading the submission to the International Maritime Organization, one may also think of Leonard Cohen’s “Everybody Knows” lyrics: “Everybody knows that the dice are loaded, everybody rolls with their fingers crossed.”
Pink Floyd comes to mind because marine did not really participate in the debate. Yes, many spoke, but they did not speak with one voice and therefore were not heard. Many looked at the proposal but few, if any, stepped back and looked at the ECA picture holistically.
Map 1, from the submission, is the proposed ECA, which covers the coasts but not Arctic waters. The Great Lakes would have ECA status as well. What will happen on the East Coast? Some bulker traffic that now goes into the Lakes will shift to Churchill (no ECA) and container traffic that comes to Montreal may go to Halifax (shorter sailing distance in the ECA) and Churchill. Why would a ship pick up grain in Thunder Bay (Map 2, black-dotted line) if it can sail into Churchill (red line) on heavy fuel oil? On the Great Lakes, the ECA will bring about a modal shift to land transport. This shift will increase local air pollution, accidents, etc.
Leonard Cohen comes to mind because the data used by Canada and the U.S. is flawed and at times seems twisted to suit the purpose.
The pre-emptive reason for the ECA is that up to 8,300 lives will be saved. In a July 2008 article in Air & Waste Management Association’s EM magazine, Environmental Protection Agency scientists state that “linking changes in emissions to human exposure and health end points (respiratory related hospital admissions, mortality effect estimates) remains to be a major area of research.” So this projection is not science but opinion.
A second article in the same issue addresses improving exposure assessments with models, going from global to regional to urban to local to human scale. Looking at air pollution from this angle, pollution starts concentrated at the tailpipe and then thins out. Therefore, as a person at the local street level, we are exposed to concentrated emissions from road and rail before they thin out into the atmosphere. This concentrated local pollution has a greater effect on our health because pollution is delivered more efficiently to our lungs. The same is true for the crane operator in a port; he has to breathe the stack emissions before they spread out.
Could data be custom-made to support the ECA proposal? Is it really possible that marine contributes more than 100 per cent of the excess in critical loading (Environment Canada graphic) in the Athabasca oilsands area? I find it difficult to believe that ships calling Vancouver and/or Prince Rupert would affect the air quality in the oilsands to such a degree. Who would have thunk?
Why not take the time to consider the bigger picture? Are we affected as badly from marine emissions as the people living around the Mediterranean or the Suez Canal or the ports of Hong Kong or Shanghai? Is our Highway H2O in the same league, traffic wise, as the English Channel?
And, ultimately, how will the proposed ECA affect the global environment? Will it improve humanity’s condition? Will it slow the melting of the polar ice caps and the Greenland ice cover? Will it slow global warming? The answer is “no” on all these counts. Worse, the ECA will actually help to speed up the melting of the ice because of increased traffic in the Arctic and thereby contribute to faster-rising sea levels, which in turn will affect millions more people in poor, low-lying areas of this world. World Health Organization research indicates that today, 115,000 deaths per year can be attributed to climate change and rising sea levels. How much will the faster-rising sea levels, caused by the proposed ECA, increase these numbers? Why not listen to WHO and first address climate change, as it sees this is the more pressing problem.
With the recent proposal by Canada and the United States for a North American Emission Control Area, Pink Floyd’s “Is There Anybody Out There?” comes to mind. When reading the submission to the International Maritime Organization, one may also think of Leonard Cohen’s “Everybody Knows” lyrics: “Everybody knows that the dice are loaded, everybody rolls with their fingers crossed.”
Pink Floyd comes to mind because marine did not really participate in the debate. Yes, many spoke, but they did not speak with one voice and therefore were not heard. Many looked at the proposal but few, if any, stepped back and looked at the ECA picture holistically.
Map 1, from the submission, is the proposed ECA, which covers the coasts but not Arctic waters. The Great Lakes would have ECA status as well. What will happen on the East Coast? Some bulker traffic that now goes into the Lakes will shift to Churchill (no ECA) and container traffic that comes to Montreal may go to Halifax (shorter sailing distance in the ECA) and Churchill. Why would a ship pick up grain in Thunder Bay (Map 2, black-dotted line) if it can sail into Churchill (red line) on heavy fuel oil? On the Great Lakes, the ECA will bring about a modal shift to land transport. This shift will increase local air pollution, accidents, etc.
Leonard Cohen comes to mind because the data used by Canada and the U.S. is flawed and at times seems twisted to suit the purpose.
The pre-emptive reason for the ECA is that up to 8,300 lives will be saved. In a July 2008 article in Air & Waste Management Association’s EM magazine, Environmental Protection Agency scientists state that “linking changes in emissions to human exposure and health end points (respiratory related hospital admissions, mortality effect estimates) remains to be a major area of research.” So this projection is not science but opinion.
A second article in the same issue addresses improving exposure assessments with models, going from global to regional to urban to local to human scale. Looking at air pollution from this angle, pollution starts concentrated at the tailpipe and then thins out. Therefore, as a person at the local street level, we are exposed to concentrated emissions from road and rail before they thin out into the atmosphere. This concentrated local pollution has a greater effect on our health because pollution is delivered more efficiently to our lungs. The same is true for the crane operator in a port; he has to breathe the stack emissions before they spread out.
Could data be custom-made to support the ECA proposal? Is it really possible that marine contributes more than 100 per cent of the excess in critical loading (Environment Canada graphic) in the Athabasca oilsands area? I find it difficult to believe that ships calling Vancouver and/or Prince Rupert would affect the air quality in the oilsands to such a degree. Who would have thunk?
Why not take the time to consider the bigger picture? Are we affected as badly from marine emissions as the people living around the Mediterranean or the Suez Canal or the ports of Hong Kong or Shanghai? Is our Highway H2O in the same league, traffic wise, as the English Channel?
And, ultimately, how will the proposed ECA affect the global environment? Will it improve humanity’s condition? Will it slow the melting of the polar ice caps and the Greenland ice cover? Will it slow global warming? The answer is “no” on all these counts. Worse, the ECA will actually help to speed up the melting of the ice because of increased traffic in the Arctic and thereby contribute to faster-rising sea levels, which in turn will affect millions more people in poor, low-lying areas of this world. World Health Organization research indicates that today, 115,000 deaths per year can be attributed to climate change and rising sea levels. How much will the faster-rising sea levels, caused by the proposed ECA, increase these numbers? Why not listen to WHO and first address climate change, as it sees this is the more pressing problem.
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